Hazardous and Solid Waste

Used Oil FAQs

The RCRA used oil management standards can serve as a road map to guide used oil handlers (generators, transporters, burners, marketers, processors, and re-refiners) through the various storage, recordkeeping, and cleanup procedures to ensure used oil is handled safely. The used oil regulations are based on the presumption that used oil (i.e., oil contaminated by chemical or physical impurities as a result of use) will be recycled. Central also to the used oil management rules is the presumption that used oil containing more than 1,000 parts per million of total halogens has been mixed with a hazardous waste, thereby requiring the used oil be handled under hazardous waste management rules.

Note. As with many regulations under RCRA, your state may have stricter requirements for used oil. Some states regulate used oil as a hazardous waste, and other states regulate it as a special waste. If your state manages used oil as a hazardous waste, you must comply with the state’s hazardous waste requirements.

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Used oil FAQs:

Q. What is the requirement for using a funnel system as a closure for a 55-gallon drum used to collect used oil? Is this requirement different for used oil versus hazardous liquid waste?

A. The federal used oil regulations do not require containers of used oil or used oil mixtures to meet the hazardous waste container requirements at 40 CFR 264/265, provided that the used oil is being managed under the used oil regulations of 40 CFR 279. The federal used oil regulations do not contain provisions regarding container funnels or whether the container must be closed. However, containers of used oil mixtures managed as hazardous wastes must be in compliance with the federal hazardous waste container requirements. The federal hazardous waste regulations require containers to always be closed during storage, except when adding or removing waste. While the hazardous waste container rules do not specifically address the use of funnels in containers, the EPA has noted that a common violation is hazardous waste drums that have been left open during a work shift, or drums with open funnels.

Therefore, it is logical to conclude that funnel systems may be used in 55-gallon drums that contain used oil and are being managed under the used oil rules. While there is no requirement that the funnels on the drums be kept shut, it is a good practice to keep them shut except when adding or removing the used oil.

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Q. Are conditionally exempt small quantity generators exempt from the used oil management standards?

A. The federal used oil management standards do not contain an exemption for any class of generators based on used oil generation rate. As a result, all used oil generators producing used oil through commercial or industrial operations and vehicle services are subject to the same uniform standards. Only the individuals listed in 40 CFR 279.20(a) (1) through (4) are exempt from the used oil generator requirements.

Q. How long can used oil be accumulated and stored at a facility?

A. The federal used oil regulations do not limit the time period for storage or accumulation of used oil at a site. However, be sure to check with your state. Some states have stricter requirements for the amount of used oil that may be stored at one time and/or an accumulation time limit for used oil.


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